Part 2A of Form ADV: Firm Brochure Item 1 Cover Page ROCHDALE ...

Item 12
Brokerage Practices
A. Factors Considered in Selecting or Recommending Broker-Dealers for Client Transactions
Rochdale considers a number of factors in selecting a broker-dealer to execute transactions (or series of
transactions) and determining the reasonableness of the broker-dealer’s compensation. Such factors
include net price, reputation, financial strength and stability, efficiency of execution and error resolution,
offering to Rochdale on-line access to computerized data regarding a client’s accounts. In selecting a
broker-dealer to execute transactions (or series of transactions) and determining the reasonableness of the
broker-dealer’s compensation, the Adviser need not solicit competitive bids and does not have an
obligation to seek the lowest available commission cost. It is not Rochdale’s practice to negotiate
“execution only” commission rates, thus a client may be deemed to be paying for research, brokerage or
other services provided by a broker-dealer which are included in the commission rate.
1. Research and Other Soft Dollar Benefits
Rochdale receives research or other products or services other than execution from a broker-dealer and/or
a third party in connection with client securities transactions. This is known as a “soft dollar” relationship.
Rochdale will limit the use of “soft dollars” to obtain research and brokerage services to services that
constitute research and brokerage within the meaning of Section 28(e) of the Securities Exchange Act of
1934, as amended (“Section 28(e)”). Research services within Section 28(e) may include, but are not
limited to, research reports (including market research); certain financial newsletters and trade journals;
software providing analysis of securities portfolios; corporate governance research and rating services;
attendance at certain seminars and conferences; discussions with research analysts; meetings with
corporate executives; consultants’ advice on portfolio strategy; data services (including services providing
market data, company financial data and economic data); advice from broker-dealers on order execution;
and certain proxy services. Brokerage services within Section 28(e) may include, but not limited to,
services related to the execution, clearing and settlement of securities transactions and functions
incidental thereto (i.e., connectivity services between an adviser and a broker-dealer and other relevant
parties such as custodians); trading software operated by a broker-dealer to route orders; software that
provides trade analytics and trading strategies; software used to transmit orders; clearance and settlement
in connection with a trade; electronic communication of allocation instructions; routing settlement
instructions; post trade matching of trade information; and services required by the SEC or a self
regulatory organization such as comparison services, electronic confirms or trade affirmations.
The Chief Compliance Officer will periodically review and evaluate Rochdale’s soft dollar practices and
to determine in good faith whether, with respect to any research or other products or services received
from a broker-dealer, the commissions used to obtain those products and services were reasonable in
relation to the value of the brokerage, research or other products or services provided by the brokerdealer.
This determination will be viewed in terms of either the specific transaction or the Adviser’s
overall responsibilities to the accounts or portfolios over which the Adviser exercises investment
discretion.
The use of client commissions (or markups or markdowns) to obtain research and brokerage products and
services raises conflicts of interest. For example, the Adviser will not have to pay for the products and
services itself. This creates an incentive for Rochdale to select or recommend a broker-dealer based on its
interest in receiving those products and services.
Rochdale may cause clients to pay commissions (or markups or markdowns) higher than those charged by
other broker-dealers in return for soft dollar benefits (known as paying-up), resulting in higher transaction
costs for clients.
Research and brokerage services obtained by the use of commissions arising from a client’s portfolio
transactions may be used by Rochdale in its other investment activities, including, for the benefit of other
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